The meaning of “should” and “shall” in the OSHA regulatory context is clear and long established.

“Should” is advisory and “shall” is mandatory.

The MeCl standard you quoted is recommending that contacts not be worm, it is not forbidding. It is not requiring some additional assessment before they can be permitted. It is merely recommending.

I believe the American Ophthalmological Association issued a position paper a good many years ago saying that use of contacts in a chemical lab is not a hazard in the vast majority of situations, but is not a
substitute for safety glasses or goggles.

Our chemistry lab currently does not allow anyone to wear contact lenses in the labs. I’d like to propose that we allow contacts under safety glasses, goggles or face shields. We do use methylene chloride, many different corrosive chemicals
and potent compounds (mostly in chemical fume hoods but sometimes on the open bench top if dilute or in very small quantities). The dilemma I’m facing is that OSHA states in 1910.1052 for Methylene Chloride that contact lenses
should not be worn when working with this chemical. I take this a recommendation not a hard rule. Some of my safety colleagues interpret “should not” to mean that contacts can be worn as long as I can prove that a
hazard does not exist (which I don’t think I can do but I feel comfortable with the risk level, citing NIOSH recommendations and scientific studies but not all studies are well enough designed to prove there is no hazard).

My hazard evaluation would include listing the chemicals that are more of a hazard and training the chemists accordingly and letting the chemists decide if they want to take the risk or decide not to wear contacts and order the prescription
safety glasses that the company will buy. Some safety people want me to limit contact lens use only for chemical use that will pose no hazards. However, in a very large lab with hundreds of chemicals that are constantly changing this would be more work than
I feel value added and would confuse the chemists leading to non-compliance.

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